[bc-gnso] Comments from Marilyn Cade: Another Last Call: BC Position - Baseline Registry Operations Report
berrycobb at infinityportals.com
berrycobb at infinityportals.com
Wed Mar 31 22:48:58 UTC 2010
Mariyln & CBUC,
I just crafted a nice response and then lost it on this crappy
hospital network, because all I have right now is web based mail
access. Excuse ye being brief and if I sound rude that is not my
intent, its frustration.
- Mariyln thank you for your feed back. It was helpful and I included
all but 2 points. Attached is the latest draft for your review.
- Discussion Point 1 - I will be happy to include what is needed here.
However, I am confused by the reasoning supplied. It only mentions
why people may register domains in a ccTLD and not in reference to
comparing an operating model from a ccTLD with other TLDs. I
understand the operating models to be drastically different both
technically and in business operations. I have very little experience
here....so I am wide open for suggested language for the "Survey
Demographics."
- Discussion Point 2 - Outsourcing of Compliance. The study reveals
that small Registries outsource their compliance. It does not suggest
that ICANN outsource its compliance. Therefore, I think the last
bullet with "Survey Demographics" in our position statement stands as
is. ICANN should take a close look as this to ensure it is done
correctly. I do not oppose outsourcing it, but doing so does increase
risk and ICANN should have a pulse as to WHEN and HOW.
Thank you for the feedback again. Please advise of any other changes.
B
Berry Cobb
infinity Portals LLC
866.921.8891
Quoting Marilyn Cade <marilynscade at hotmail.com>:
>
>
> Barry, Steve,
> Thanks Barry, for your work on this. I have a couple of
> suggestions, and point out a couple of editorial changes that you
> will want to make. I provide several suggestions ,and put into bold
> some of the key words/and new proposed language to try to make this
> easier to understand and follow.
> Overall great job. A few critical changes proposed.
> For the longer term, I know that there are other discussions to be
> had about a 'template' or 'templates' for BC policy positions and,
> I do hope that you will play a leadership role in that process.
> On the substance of this comment, I would suggest that you change
> the legend on some of the elements to !. For instance, although the
> category: "Reserves" says no comment, actually the BC does have a
> comment. Capital Expenditures: says no comments, but does offer a
> very important comment. Continuity Planning, legend says no comment,
> but we do have a comment. I'd just suggest changing the legend to
> "!", and editing out the /NO comment on those issues.
> Finally, I wanted to call your attention and others to the need to
> have a category that is 'brands related gTLD registry'. Youcould
> add a footnote to 'registry population', noting that there may be a
> category of registries that are operated by a brand holder, for
> their subscribers, or employees, and that this category is not
> addressed, to date, in ICANN's work.
>
>
> In the Survey Demographics section. The first bullet point needs to
> have an edit in the last reference to the ccTLDs. it should read
> "..... under different contractual obligations to ICANN than ccTLDs.
> I think you mean ... "than gTLDs".
> Discussion Point: I spent a good deal of time studying ccTLDs when
> I was chairing the first WHOIS Task Force. The working methods of
> the cc's are indeed a good barometer for learning. Sometimes this is
> not well understood by business users who primarily register in
> cc's defensively. And, there are other factors that limit the
> exposure of business users to the ccTLD managers -- e.g. while we
> once held dialogues with the cc's that has gone by the wayside and
> the primary focus is on the gTLDs. And, then the reality is that
> the gTLDs registries often believe that they are the 'rightful
> choice' for back engines for future gTLDs and even for ccTLDs. As
> BC, we need to agnostic about business preferences. Business uses
> can register in either gTLDs or ccTLDs and need to have a broadened
> understanding of the role and activities of the ccTLDs for many
> reasons. I'd propose that we soften the comments about the cc's.
> For instance, I disagree with the proposal that the review of cc's
> be limited to those ccTLDs that mimic gTLDs -- I do not agree. That
> would eliminate .de; .uk, and .ca, and .cn, for example, all of
> which are large and complex ccTLDS, often more complex and
> technically sophisticated than many of the smaller gTLDs. A few
> cc's are marketed as 'global' TLDs, and that has disconcerted, or
> annoyed some gTLD registries. That is a perspective of gTLD
> registries that may not not actually serve the broader global
> business user communities' interest. For instance, if you are a
> small Kenyan business, you may both prefer to register in .ky and
> find advantage in doing so. You may also want to register in a gTLD
> as well, however. Global business users are registering in ccTLDs in
> many cases to have identity in the country they are doing business
> in. Understanding cc's practices is a 'good thing'.
> I'd prefer to strike the statement "Perhaps ccTLDs that mimic a gTLD
> should be chosen'. Instead, I'd propose that the BC statement
> read: The CBUC supports the inclusion of ccTLDs in this study and
> is interested in ensuring that the sample is fully representative
> of different practices and models, including analyzing different
> 'sizes" of cc TLD registries.
> In your bullet about slide 4, the language seems to need some editing.
> Finally, I do not support ICANN's outsourcing of compliance, and I
> suggest that the BC should not support that. The present position
> offered could be strengthened by changing the statement to proposed
> new statement:
> "Enforcement and compliance should remain a primary function of
> ICANN itself. Outsourcing of such functions may create
> vulnerabilities for ICANN to fulfull its core responsibilities and
> any proposed outsourcing should be carefully studied, and the
> subject of further public comment before proceeding with any such
> initiatives. ICANN may be proposing an initial cost savings approach
> that will ultimately harm the registrants and limit ICANN's ability
> to fulfill its core responsibilities. "
> Technical and Network Architecture: This BC statement could use the
> same footnore reference mentioned above regarding brands registries.
>
>
>
>
>> Date: Tue, 30 Mar 2010 18:57:58 -0400
>> Subject: [bc-gnso] Another Last Call: BC Position - Baseline
>> Registry Operations Report
>> From: sdelbianco at netchoice.org
>> To: bc-GNSO at icann.org
>>
>> Another Last Call before closing on a BC comment.
>>
>> Attached is the draft BC position regarding the report on Baseline Registry
>> Operations.
>>
>> Berry Cobb circulated the draft back on 23-Mar (see below). I¹ve signaled
>> my agreement.
>>
>> Absent objections by COB tomorrow, we will file as consensus BC comments on
>> 1-Apr-2010.
>>
>> --Steve
>>
>> On 3/23/10 3:16 AM, "Berry Cobb" <berrycobb at infinityportals.com> wrote:
>>
>> BC,
>>
>> Attached is the first draft of the CBUC position statement for the Baseline
>> Registry Operation report released by ICANN. Overall, I feel KPMG performed
>> well and provided meaningful views of the data. It is ashamed that more
>> participants were not a part of the sample data.
>>
>> My Registry operations experience is limited, so I ask the BC team to take a
>> strong look at the report and the initial comments I provided. I especially
>> invite our members that have direct Registry operations experience
>> to enhance our position about this study and its future use by the gTLD
>> Evaluation teams.
>>
>> This material is sure to have a direct impact to the next Draft Applicant
>> Guidebook version 4 to be released just prior to Brussels. In a
>> quick review, the following are what I believe to be sections of the DAGv3
>> where this study could influence the Application Evaluation Criteria, or
>> the Application Process both of which will be used by the gTLD Evaluation
>> teams.
>>
>> 1.2.2 Required Documents for Application
>> 1.4.2 Application Form
>> 2.1.2 Applicant Reviews
>> 2.1.3 Registry Services Review
>> 2.2.1 Technical/Operational or Financial Extended Evaluation
>> 2.2.2 DNS Stability Extended Evaluation
>> 2.2.3 Registry Services Extended Evaluation
>>
>> The comment period closes April 1st, so I ask for your quick
>> turn-around. As Steve DelBianco eluded to in our last BC call, there are a
>> large number of comment period closings converging at once. I thank you for
>> your quick response. I will compile all feedback and incorporate changes on
>> 3/30/2010.
>>
>>
>> Berry Cobb
>> Infinity Portals LLC
>> San Jose, CA
>> mailto:berrycobb at infinityportals.com
>> http://infinityportals.com <http://infinityportals.com/>
>> 866.921.8891
>>
>>
>
>
>
>
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